The new §1.951A

For those who have been reading my blogs, you know about my submission on the proposed Treas. Reg. §1.951A. (Click here for the submitted comment). I'm happy to announce that the Treasury department have adopted the a pure-aggregate approach. This is the same approach that was supported in my comment.
Breakdown: the pure aggregate approach allows partners the ability to offset their GILTI income inclusion with GILTI losses. Under the proposed approach, the aggregate approach was only applicable to 10% partners (large partners). Although there was major push back from the State Bar of Texas, I went ahead and submitted the comment anyways.
I'm happy to say that Treasury realize that the proposed approach was highly unfair and have adopted the pure-aggregate approach. This approach therefore allows less than 10% partners (small partners) the ability to offset their GILTI inclusion as well. Click here to read Treasury's comment on the new regulation.